22c-2 Compliance Insight Services

The experienced Insight Services group at Access Data enables mutual fund companies to outsource operational and analytical activities that support 22c-2 compliance monitoring and reporting. Working with your operational compliance team, Access Data business experts will provide a “best practices” approach to the construction of your 22c-2 shareholder compliance rules, workflows, and analytics as well as the interpretation of your reporting. Access Data will also maintain and monitor a set of control reports used to provide oversight on all 22c-2 related data requests, responses, processing, analysis, and enforcement activity performed by the Insight Services group up to and including restriction notification and confirmation.

Daily Operational Tasks

On a daily basis, the Insight Services group will monitor omnibus account activity and individual shareholder excessive short-term trading, reporting any suspicious activity or rule violations that are detected. The following is a list of what Access Data will do to enhance your 22c-2 compliance monitoring:

• Work with the CCO to construct compliance rules and statistical analyses
• Monitor daily violations as created by the overnight batch process
• Provide standard reports to the operational compliance team
• Provide development and support for the creation of customized compliance queries
• Maintain reports for the CCO, Board, management company, and regulators
• Manage data requests via the NSCC, web portals, or other secure file transfer protocol
• Provide ongoing development and support for specific detailed controls and reports
• Monitor daily control reports to provide oversight of the 22c-2 Insight Services group
• Maintain key data-sharing methods for each intermediary
• Maintain each intermediary’s restriction communication methods
• Act as agent on behalf of fund for initiating account warnings and/or restrictions
• Receive confirmation of account restrictions and record confirmation details
• Investigate restriction requests that are rejected or not confirmed in a timely fashion
• Escalation to intermediary and/or fund compliance personnel when necessary